4 Steps to Preventing and Managing Recalls
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1
Know How to Prevent and Manage Recalls
- Follow safety practices. Use Hazard Analysis Critical Control Points, Good Manufacturing Practices, Good Agricultural Practices or total quality control principles to prevent recalls.
- Label products clearly. Put code dates on finished products so your team can trace them back to the exact day of production.
- Keep detailed records, especially for formulated product. Link ingredient lot numbers or code dates to your finished product codes. This makes it easier to track products if a supplier starts a recall.
- Know your risks. Understand possible contaminants — microbial, chemical, or physical — that could affect your products.
- Work with regulatory agencies. Decide together what counts as “affected product.” This could include all products with an ingredient from one source, or everything made between cleanings or processing breaks.
- Identify recall scope. Both the contaminant and in-plant controls help determine which products are subject to recall.
- Documentation is key! Detailed records, proven cleaning steps to create a clean break between batches and validated pathogen reduction processes can limit how much product must be recalled.
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2
Build a Strong Recall Plan through Advance Planning
- Assign responsibility. Every food producing company should have a person or committee in charge of handling contamination events (intentional or accidental) and recalls. One person should be the main contact with regulatory agencies. Decide in advance how your company will respond to Class I, II or III recalls.
- Write it down. Create a written recall procedure so others can carry it out if key staff are unavailable.
- Track products. Review your shipping and receiving records to make sure you can quickly trace shipments. Keep updated contact information for all your business partners. Work with customers who redistribute your products to understand their recall procedures. Prepare a backup plan in case they cannot track distribution.
- Plan storage. If you don’t have enough on-site storage for recalled items, arrange secure off-site storage ahead of time. Limit access to authorized staff only. Check and update your access list every quarter.
- Plan disposal. Identify safe disposal options, like landfills or incineration, that are approved by environmental and waste agencies to prevent recalled products from being misused.
- Assign a spokesperson. Choose a public relations representative before an event happens. This person should be ready to talk to the media and send out accurate, timely messages.
- Consider reworking. If products can be reworked, line up contacts who can help before you ever need them.
- Keep records. Set up a system to log and track recalled products.
- Practice your plan. Run a mock recall to test your system and find weaknesses before a real event.
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What to Do When a Recall Occurs
- Assign staff. Choose drivers, shipping and receiving staff, and clerks who can step in quickly to handle the physical recall.
- Give clear instructions. Provide fast, accurate recall directions to everyone in the distribution chain.
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4
Review your plan regularly.
Check your recall process, note any weak spots and fix them in advance.